8 replies to this topic

[RTP]

Hello,

 

We have identified certain ingredients (Chocolate, Cocoa, gums, sweetened condensed milk, tree nuts etc) as sensitive ingredients and have it as one of our CCPs. The reason for categorizing them as sensitive is because all these ingredients will be used in our process as icing or decoration on the cakes which will not undergo any cooking to kill some of the microbes.

 

Now, when we receive ingredients that contain one or more of the ingredients that we have listed as sensitive, would that make this ingredient sensitive or not? In my opinion I think it depends, the reason is if those sensitive ingredients have undergone kill step to make this final ingredient then we need not consider it as sensitive.

 

Example, we have listed cocoa and sweetened condensed milk as sensitive because we do not cook these ingredients and are used in making RTE toppings. However if we do receive Chocolate icing as one of our ingredients and it contains both ingredients such as  cocoa and sweetened condensed milk, now would the chocolate icing become a sensitive ingredient or not?

 

Please share your experiences and help me understand better.

 

Thank You.

RTP

[brblack2454]

Hi RTP

 

Yes if you receive chocolate icing and it has the milk and cocoa it would need to be considered as if you were making the chocolate icing yourself to be consistent with your policies & procedures. The only way around this is if you can find out from the supplier of the chocolate icing if the manufacturing process eliminated the need for you to consider it once in your facility. Of course you would need to keep written documentation.

 

Question: Your use of the sweetened condensed milk is not classified in your facility as an allergen rather than a sensitive ingredient? From my understanding the condensed milk is an allergen containing item (part of the Big 8 in the US) rather than a sensitive ingredient. As far as the cocoa we manufacture a chocolate dessert tamale in my facility and have not defined cocoa as a sensitive ingredient because in the U.S. it isn't viewed as containing any sensitive ingredients. On the other hand we use chocolate chips in the tamale manufacturing process and the chips we use do in fact contain a milk allergen. My suggestion would be to review the ingredients in the cocoa and condensed milk and verify with the manufacturer whether to define as sensitive or allergen.

 

Hope this helps

 

Brblack

[RTP]

Hello Brblack,

 

Thank you for your input, I really appreciate it.  We do identify and segregate allergens and yes we consider Sweetened condensed milk as an allergen.

[Ryan M.]

You really need to dig into how your suppliers are processing the materials.  Just because you don't use a kill step does not make the material sensitive in your process.  For example, the cocoa and the gums, I'm assuming they are dried with low water activity?  This makes them far less risky than you think, especially if you only hydrate them just prior to using.  I'm also assuming all of your cakes after icing are chilled or frozen?  This eliminates a lot of risk as well. 

 

My point is that just because something isn't going through a kill step does not mean you have to classify as a CCP in your plan.  Doing so could add a lot more work than you really need and make it quite complicated. 

 

Do more analysis around the materials/ingredients you use and really get to know the process.

[Charles.C]

You really need to dig into how your suppliers are processing the materials.  Just because you don't use a kill step does not make the material sensitive in your process.  For example, the cocoa and the gums, I'm assuming they are dried with low water activity?  This makes them far less risky than you think, especially if you only hydrate them just prior to using.  I'm also assuming all of your cakes after icing are chilled or frozen?  This eliminates a lot of risk as well. 

 

My point is that just because something isn't going through a kill step does not mean you have to classify as a CCP in your plan.  Doing so could add a lot more work than you really need and make it quite complicated. 

 

Do more analysis around the materials/ingredients you use and really get to know the process.

 

Hi rmills,

 

The problem is that there are a multitude of recorded incidents caused by "post-killing" contamination.

 

This tends to necessitate/auto-classify ingredients added at such stages as high risk items together with the environment. For example -

 

 Post elimination contamination.png   352.34KB   11 downloads

 Post elimination contamination (2).png   246.34KB   6 downloads

[Ryan M.]

Hi rmills,

 

The problem is that there are a multitude of recorded incidents caused by "post-killing" contamination.

 

This tends to necessitate/auto-classify ingredients added at such stages as high risk items together with the environment. For example -

 

Post elimination contamination.png

Post elimination contamination (2).png

 

While true, it doesn't mean in all cases, all processes, and all products they are sensitive or highly hazardous materials.  My point, the OP needs to do further analysis at the vendor/supplier to determine how they are processing/handling those materials prior to the OP receiving them.  Then look at their current controls in place in their process through shipping/distribution and with the end consumer handling.  Only then can they determine what is/should be handled as a CCP.

It isn't a one size fits all and I think more often than not, people over classify the number of CCP's in their process when they really should be focusing more effort on sound pre-requisite program.

[Charles.C]

Hi rcmills,

 

I agree PRPs are a crucial control measure for food safety but i wonder if, as illustrated in the iso22002 standard, the trend has now gone so far that it has diminished the ability to focus on demonstrated risk factors.

 

From a traditional HACCP/CCP POV this equates to deciding what is a significant process hazard for a RTE finished product.

 

FSMA has its own viewpoint on this of course.

[erasmuskoay]

Just wish to state my opinion based on a submission where I noted the conclusions were marked as "CCP" and "sensitive raw material" as opposed to "Not a CCP" and may be "sensitive raw material" or not.
 

Are we examining a Critical Control Point [CCP] and / or a sensitive material for raw materials or packaging materials?
 

The definitions provided in the Standard are:

Critical control point - A point, step, or procedure in a food process at which control can be applied and, as a result, a food safety hazard can be prevented, eliminated, or reduced to acceptable levels.

Sensitive raw materials/ingredients – Materials forming part of a product, e.g. primary produce, additives, processing aids as well as packaging and similar materials that could result in an unacceptable food safety risk to consumers and need to be controlled.
 

Issue #1.

In key discussions and literature review, users are worried about assessment of risks and leading to identification of additional CCPs and lot of additional monitoring as well as effective control measures. As such, with so many attempts to recognised allergens caused by Big 8 including eggs, milks and nuts as its own hazard #4 was widely discussed – and should be categorised under physical or chemical matters. No one can safely estimate what is the critical limits to a consumer as the tolerance level of individuals differ. The best is zero raw materials that are sensitive to every consumers in terms of food safe for consumption.

Issue #2.
 

Clause 5.2.4.3 provides the use of Figure 2a, which shall be used as guidance when determining CCPs. However, in Figure 2a logic reasoning path do not provide assertions to identifying and confirming a CCP.
 

In the case of a raw material e.g. cocoa powder and dairies which can cross-contaminate an entire facility or to other products will not be controlled, then CCP is required to monitor the activity. However the likelihood of users to answer – “no” there is no chance of cross-contamination due to control measures taken has eliminated the item as sensitive raw materials to cross contaminate does not eliminate the product being sensitive itself.
 

My conclusion,

Clause 5.2.4.3 is defective due to its circumstantial provision of logic reasoning. Raw ingredients, raw materials or packaging materials should only limit itself to identification as being sensitive or not. It should not tantamount to having determine that there is a Critical Control Point. The recognition of a CCP should remain in process steps of a facility rather of the materials.

Erasmus Koay,
FSSC Lead Auditor.
MIENS

[Charles.C]

Clause 5.2.4.3 provides the use of Figure 2a, which shall be used as guidance when determining CCPs. However, in Figure 2a logic reasoning path do not provide assertions to identifying and confirming a CCP.

 

 

Where are they ?
 

 

The definitions provided in the Standard are:

 

 

Which Standard ?

 

5.2.4.3, Fig.2a, "sensitive ingredients" seem absent from iso22000